Ayala v. Commissioner of Social Security
- Paul Engelmayer
- 1:19-cv-03318
- U.S. District Court · Southern District of New York
- 2
In Ayala v. Commissioner, Judge Engelmayer reversed and remanded the decision denying A.A. Supplemental Security Income benefits for further proceedings about psychiatric impairments.
Minor A.A.’s claim for Supplemental Security Income benefits was sent back to the Commissioner for further administrative proceedings concerning psychiatric impairments and treatment records.
What happened
Ayala v. Commissioner of Social Security concerned a challenge by Yemalia Ayala, on behalf of minor A.A., to an administrative law judge’s decision finding A.A. ineligible for Supplemental Security Income benefits.
Judge Kevin N. Fox recommended reversing and remanding the decision so the record could be developed concerning A.A.’s psychiatric impairments, including obtaining psychiatric treatment records. No party objected to that recommendation.
Judge Engelmayer reviewed the recommendation for clear error, adopted it in full, and reversed and remanded the administrative decision to the Commissioner for further proceedings. The court terminated the pending motion and closed the case.
The detailed version
- Ayala v. Commissioner of Social Security · No. 1:19-cv-03318
- Paul Engelmayer
- Jan. 27, 2020
Background
Yemalia Ayala sued on behalf of minor A.A. to obtain judicial review of an administrative law judge’s May 2, 2018 decision finding A.A. ineligible for Supplemental Security Income benefits under Title XVI of the Social Security Act. The Commissioner filed an unopposed motion for judgment on the pleadings under Federal Rule of Civil Procedure 12(c).
The case had been referred to Magistrate Judge Kevin N. Fox. On January 3, 2020, Judge Fox issued a Report and Recommendation advising that the administrative law judge’s final decision be reversed and remanded to the Commissioner for further administrative proceedings. The recommended remand was intended to develop the record concerning A.A.’s psychiatric impairments, including by obtaining psychiatric treatment records.
District Court’s Review
Because neither party objected to the Report and Recommendation, the district court reviewed it for clear error on the face of the record. The court found no such error and adopted the Report and Recommendation in its entirety. The opinion also states that the parties’ failure to object waived appellate review, consistent with the warning in the Report.
Ruling
Judge Engelmayer ordered that the administrative law judge’s final decision be reversed and remanded to the Commissioner for further administrative proceedings under 42 U.S.C. § 405(g). The order directed the Clerk of Court to terminate the motion pending at docket 13 and close the case. The opinion did not itself award Supplemental Security Income benefits; it required further administrative proceedings.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.